Thompson v. Brown

Dist. Ct. erred in dismissing defendant’s habeas petition that challenged his 1982 murder conviction, even though record showed that defendant had filed post-conviction petition in 1992, which incurred series of delays caused by defendant and was ultimately denied on laches grounds in 2014. Dist. Ct based instant dismissal on belief that defendant had procedurally defaulted underlying claims of ineffective assistance of counsel and double jeopardy, because denial of post-conviction petition on laches grounds was adequate and independent state-law ground of decision that barred Dist. Ct. from reviewing merits of any federal claim. Ct. of Appeals, though, found that dismissal was inappropriate, because there was no firmly established and regularly followed Indiana rule that laches applied to delays to already-filed actions, as opposed to yet-to-be filed actions. On remand, Dist. Ct. could explore issue as to whether any failure to prosecute post-conviction petition was alternative ground for finding procedural default in instant habeas claim.